Gustafson's Dairy, Inc. - Page 44

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          additional facilities if petitioner increased its herd to 7,500             
          cows.  We disagree.  The existing facilities (including a milking           
          parlor that could accommodate 10,000 cows) needed to be                     
          modernized or replaced, and petitioner planned to expand its herd           
          to 9,000 cows.                                                              
               Respondent argues that most of the capital assets petitioner           
          bought during the years in issue were items that petitioner                 
          bought each year, such as trucks, loaders, and refrigerators, and           
          were not assets bought as part of a capital expansion program.              
          Respondent argues that petitioner incorrectly counted this need             
          for funds both in its working capital calculations and in the               
          capital improvements category.  We need not decide whether                  
          petitioner included this need for funds both in the capital                 
          improvements category and in the working capital category because           
          we have not separately considered petitioner's working capital              
          needs.                                                                      
               Petitioner's category one and two expenses projected for               
          equipment and construction were generally less than its actual              
          expenses for those purposes during those periods.  Actual                   
          expenses in category one exceeded projected expenses by $305,043            
          for 1987, $2,335 for 1988, and $447,859 for 1989.  In category              
          two, actual expenses exceeded projected expenses by $355,194 for            









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